Fluoride Action Network

The EPA’s Shocking Timeline of Failure on Fluoride (1986-2017)

Fluoride Action Network | Bulletin | December 12, 2017

Our current totals for the 2017 FAN Fundraiser are $37,455 from 149 supporters. Our efforts over the weekend were helped by a very large donation, which is allowing us to double the next $5000 we receive.  So, today and a few days beyond your donations will go twice as far.

To add further excitement, a second super angel says that if we can reach $40,000 by midnight EDT tomorrow (Dec. 13) he will donate an additional $1000.

Click on the picture below to hear a special message from Paul Connett on the EPA hearing (Dec 8, 2017):

Within a few days we should be well on our way to reaching our mini-goal of $120,000 by midnight Christmas Eve. You can follow the excitement and watch these numbers grow via our webpage www.FluorideALERT.org -see the first revolving masthead.

How to Donate:

You can make a donation at our secure online server, or by check, payable to Fluoride Action Network, and mail to:

c/o Connett
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The EPA’s Shocking Timeline of Failure on Fluoride (1986-2017)

Under the Safe Drinking Water Act (SWDA) the EPA is required to determine a safe drinking water goal (otherwise called a Maximum Contaminant Level Goal or MCLG) to protect the public from harm using the best science available and applying an adequate margin of safety to protect the most vulnerable.  The EPA also determines a MCL (Maximum Contaminant Level) which includes economic costs for removal of contaminants exceeding the MCL.  Only the MCL is legally enforceable.

Here is the timeline from 1986 – 2017 which provides the long sordid history of how the EPA Office of water has avoided living up to these requirements leaving the US population unprotected from fluoride exposure through the water supply.

  • 1986. Despite objections from scientific personnel, EPA administrators under political pressure, forced through an unscientific MCLG and MCL of 4 ppm. This is nearly three times higher (i.e. less stringent) than any other jurisdiction in the world (the equivalent standard for Mexico and Canada and the World Health Organization (WHO) guideline are all set at 1.5 ppm). To do this the EPA chose an end-point of crippling skeletal fluorosis – the final stage of skeletal fluorosis not the earliest stage, which has symptoms identical to arthritis. There were many other problems with this determination, which we describe in detail in our book The Case Against Fluoride.
  • 2003. Although the MCLGs and MCLs for contaminants are supposed to be reviewed every 6 years, EPA’s Office of Water didn’t get around to doing this for fluoride until 2003. In 2003, they paid the National Research Council of the National Academies (NAS) to do this review for them.  The National Research Council appointed a 12-member panel, and in a rare moment of integrity, the panel chosen was well-balanced, consisting of 3 pro-fluoridation experts, 3 anti- and 6 undeclared. The NAS expected to take one year on this review it ended up taking three and half.
  • 2006. The NAS review on the toxicology of fluoride was published in March, 2006. It was extremely thorough. They looked at animal and human epidemiological studies, biochemical studies, clinical trials and even mechanistic models. It contained nearly 500 pages and about 1100 references. The panel concluded that the 4 ppm MCLG and MCL were not protective of health and recommended that the EPA do a new risk assessment.
  • 2006. The EPA dragged its feet and missed that 6-year review period.
  • 2011. The EPA kept dragging its feet until finally in 2011 they released a partial risk assessment in 2 parts (Exposure and Source and Dose-Response for Non-cancer Effects).  The end point chosen for this assessment was severe dental fluorosis. EPA claimed if a child was protected from severe dental fluorosis, the level chosen would also protect both children and adults from damage to the bone and every other tissue. Using this approach EPA produced a safe reference dose (RfD) of 0.08 mg F/kilogram bodyweight per day. Ironically, even though the NRC had told them that the MCLG was not protective, the RfD was actually increased from the previous IRIS value of 0.06 mg/kg/day!
  • 2011. FAN’s scientists submitted a very thorough critique of this risk assessment Exposure & Source and Dose Response for Non-cancer effects) on two main fronts:

1) that severe dental fluorosis was not the most sensitive end point of harm. We pointed out that the end point of neurotoxicity was more sensitive than severe dental fluorosis; that children in several Chinese studies had their IQ lowered without showing signs of severe dental fluorosis, including children with very mild, mild and moderate dental fluorosis.

2) Even assuming that severe dental fluorosis was an appropriate end point, the methods the EPA used to derive the RfD were full of holes with inadequate (even non-existent) safety margins to protect the most vulnerable.  For example, they used Dean’s studies from the 1940’s to estimate what dose caused severe dental fluorosis and then applied this figure to the whole USA population without using any safety factor to allow for the large range of sensitivity in a large population. This failure was so obvious because there were no Black or Hispanic children in Dean’s studies and it is well-known (see Table 23 at CDC, 2005) that Black and Hispanic children have a higher prevalence of dental fluorosis than White children. In their analysis the EPA also excluded children from 0-1 year. The suspicious would assume that this was done because a bottle-fed baby (where formula is made up with fluoridated water) would exceed the safe reference dose (RfD) of 0.08 mg/kg bodyweight/day!

  • 2011 – present. As per usual the EPA completely ignored FAN’s submission. However, they never used their derived RfD to determine a new MCLG or MCL or publish them as a Final Rule for public comment. In other words, they never completed the 6-year review process that they started in 2003. Nor have they started or completed any other since.
  • 2014. After the FAN conference in Crystal City in Sept 2014, a team consisting of Quanyong Xiang (lead author of the key IQ study, Xiang et al., 2003a, and 2003b), Dr. Bill Hirzy (former EPA senior scientist specializing in risk assessment); Chris Neurath (FAN’s research director) and myself, met with Peter Grevatt, Director of EPA’s Office of Ground Water and Drinking Water and another official at the EPA HQ. We explained the issue of neurotoxicity being a more sensitive end point than severe dental fluorosis and Bill Hirzy provided them a preliminary quantitative risk assessment based upon Xiang’s work (Bill’s paper was published in 2016). Grevatt promised he would share this information with other staff at the EPA and get back to us. He never did, despite several requests from Hirzy.
  • 2017. On January 11, the EPA published a Proposed Rule on their Third Six-Year Review, and essentially admitted that they had failed to finalize any 6-Year Review of fluoride since 1986, stated that further assessment of fluoride’s toxicity was of “low priority.” Thus, the US continues to operate under a highly controversial MCLG and MCL of 4 ppm established in 1986 – even though the National Research Council review of 2006, which the EPA itself requested and paid for by the US taxpayer, concluded that this MCLG and MCL were unprotective of health!
  • 2017. In September, a very important IQ study (Basash et al.) was published in Environmental Health Perspectives. This 12-year, government funded study was conducted by a top-notch group of highly experienced scientists from several universities with about 50 papers between them on similar studies on other neurotoxic substances – essentially vindicated FAN’s nearly 17-year concern on this as well as Bill Hirzy’s risk assessment calculations. What a pity that Peter Grevatt and his colleagues did not take our input seriously in Sept. 2014 (see above).

Thanks everyone for your financial support to help us rid the world of water fluoridation and return some integrity to the regulatory bodies and health agencies that are paid to protect our health and the environment.  Thank you for everything else you are doing to further these goals.

Thank You,

Paul Connett, PhD
Senior Advisor
Fluoride Action Network

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